- 22 - 448(d)(7)(C) attempt to fill the gaps by requiring both hospital and nonhospital businesses that either cease to engage in the trade or business to which a section 481(a) adjustment relates or terminate existence prior to the end of the spread period to take into account in the year of cessation or termination any remaining portion of the section 481(a) adjustment. Under such circumstances, the Chevron rule prevents us from substituting our own construction of section 448 if the Commissioner's interpretation is reasonable. Peoples Fed. Sav. & Loan Association v. Commissioner, 948 F.2d at 300. Are the Regulations Valid? Final regulations interpreting section 448(d)(7)(C) are provided in section 1.448-1(g), Income Tax Regs.10 The final 9 (...continued) change pursuant to the provisions of secs. 1.446-1(e)(3) and 1.481-5, Income Tax Regs., that would prevent a taxpayer from escaping forever taxation upon income previously deferred under the hybrid method. 10 Sec. 1.448-1(g), Income Tax Regs., provides in pertinent part as follows: (g) Treatment of accounting method change and timing rules for section 481(a) adjustment--(1) Treatment of change in accounting method. * * * (2) Timing rules for section 481(a) adjustment--(i) In general. Except as otherwise provided in paragraphs (g)(2)(ii) and (g)(3) of this section, a taxpayer required by this section to change from the cash method must take the section 481(a) adjustment into account ratably (beginning with the year of change) over the shorter of-- (A) The number of taxable years the (continued...)Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
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